White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

Justification for the use of Surrogate data at 

Joslyn Manufacturing and Supply Co. 

April 2014 

Sam Glover, Dave Allen, and Jim Neton 

Page 1 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

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White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

In response to a request by the Advisory Board on Radiation and Worker Health (ABRWH), NIOSH has 

evaluated the use of surrogate data at Joslyn Manufacturing and Supply Co., (Joslyn) for the time period 

of August 1, 1948 through December 31, 1952. Specifically, the use of inhalation exposure distributions 

during this period that are provided in TBD-6000 (Battelle 2011) were evaluated against the elements 

contained in the Advisory Board’s Criteria for the Use of Surrogate Data1

 (ABRWH 2010). This 

justification of use of surrogate data at Joslyn supports NIOSH’s position that dose reconstructions during 

this time period can be performed with sufficient accuracy (NIOSH 2012, NIOSH 2014). 

Introduction 

Joslyn, located in Fort Wayne Indiana, was an important facility for the early production of uranium for 

the Manhattan Engineer District (MED) and later the Atomic Energy Commission (AEC). During the 

course of their operations well over a million pounds of uranium were handled at the facility. Early 

operations were in support of the effort to load the Hanford reactor with its initial charge of uranium and 

also consisted of applied research in how to roll and machine uranium metal for production of plutonium. 

Joslyn’s highest production rates actually occurred during the first 7 months of 1948 as they rolled 

uranium as part of the Dimensional Stability Program that sought to reduce the down time of the Hanford 

reactors during the increased power upgrades. These reactor outages were attributed to the specific 

characteristics of uranium that was produced by extrusion. The AEC hoped that rolling uranium would 

improve the reliability and loss of reactor time caused by fuel failures that plagued them in 1947 and 

1948. 

Joslyn continued as one of the principal uranium production facilities until July 31, 1948, at which point 

Simonds Saw and Steel Co., became the uranium production facility for the AEC. From August 1948 

through the end of 1952, Joslyn continued to support the AEC by rolling and machining smaller quantities 

of uranium, principally for research purposes. 

NIOSH and its support contractor Oak Ridge Associated University Team (ORAUT) have collected a 

substantial amount of information on the quantity, operation details, and facility monitoring data 

regarding the MED and AEC activities at Joslyn from 1943 through 1952. While the operations varied 

over time, they typically included various machining and rolling operations of uranium in support of the 

MED and the AEC. Over the course of its operations this included hot rolling, quenching, Medart 

straightening, cooling, grinding, waste burning, and abrasive cutting of natural uranium billets into metal 

rods. 

Monitoring data for the Joslyn facility is limited. While there were a handful of air monitoring samples 

taken in 1943 and 1944 by the MED using electrostatic precipitation methods, these were deemed 

unsuitable for use in dose reconstruction because of uncertainties in the methods. During the 1948-1952 

time period evaluated in this document, NIOSH is aware of only three set of air monitoring data. This 

1

Although NIOSH also has criteria for evaluation of the use of surrogate data that are discussed in IG-004 (NIOSH 2008), the 

 ABRWH’s criteria were used in this evaluation. A review of the NIOSH criteria against those of the ABRWH indicated that the 

Board’s criteria were inclusive of all the evaluation points contained in NIOSH’s IG-004. 

Page 2 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

includes a small data set collected by the AEC’s Health and Safety Laboratory (HASL) in 1951 that 

focused on machining operations, including samples taken at the cutoff machine and the centerless 

grinder (SRDB 11036 pdf pages 23-24). In 1952 HASL (Klevin 1952) collected samples that evaluated a 

much broader set of rolling and machining operations, which included a determination of the Time 

Weighted Average (TWA) daily intakes for various groups at Joslyn. The third data set was from a precleanup survey that measured the contamination at Joslyn in August of 1949; nearly a year after the 

highest production had ended at Joslyn (Picot 1949). 

Evaluation against the Criteria for Usage of Surrogate Data 

In light of the operations and the available monitoring data described above, this document provides an 

evaluation for applying the surrogate data contained in TBD-6000 to reconstruct routine inhalation 

intakes of uranium at Joslyn Manufacturing and Supply Company. This usage is evaluated in accordance 

with the criteria established by the ABRWH specifically for the period August 1, 1948 through December 

31, 1952. 

1)	 Hierarchy of Data – It should be assumed that the usual hierarchy of data would apply to dose 

reconstructions for that site (Individual worker monitoring data followed by co‐worker data followed 

by workplace monitoring data such as area sampling followed by process and source term data.) This 

hierarchy should be considered when evaluating the potential use of surrogate data. Surrogate data 

should only be used to replace data if the surrogate data have some distinct advantages over the 

available data and then only after the appropriate adjustments have been made to reflect the 

uncertainty inherent in this substitution. 

A detailed review of records and worker interviews at Joslyn indicate that no individual monitoring data 

for uranium were ever collected. Facility monitoring data in the form of air samples was collected on a 

limited set of machining operations in 1951 by the AEC’s Health and Safety Laboratory (HASL) and a 

more comprehensive collection with the development of Time Weighted Average daily intakes was 

performed by HASL in January 1952. 

NIOSH has determined that the data contained in the 1951 and 1952 studies meet the analytical and 

methodological requirements necessary to perform dose reconstruction as they were conducted using the 

well understood methods employed by the AEC’s Health and Safety Laboratory. These data, however, 

only represent two “snapshots” of the levels of airborne uranium over more than a three year exposure 

period. Therefore, NIOSH has used the measured data from the rolling operator and machining operator 

from TBD-6000 to augment the limited air samples at Joslyn. 

2)	 Exclusivity Constraints – In many cases, surrogate data are used to supplement the available 

monitoring data from a site. In those cases, the surrogate data is usually used to justify certain 

assumptions about the distribution or range of possible exposures or assumptions about the source 

terms. In those cases, no special justification is necessary beyond the usual scientific evaluation. This 

is akin to the Type II use described above. However, in other situations, there are no or very little 

monitoring data available. In those cases, the use of the surrogate data as the basis for individual 

Page 3 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

dose reconstruction would need to be stringently justified. This judgment needs to take into account 

not only the amount of surrogate data being relied on relative to data from the site but also the 

quality and completeness of that surrogate data. 

As discussed above, data collected by HASL in 1951 and in particular 1952 are available for evaluating 

internal dose from uranium rolling and machining operations at Joslyn. NIOSH, however, utilized the 

surrogate data from TBD-6000 to describe the full range of conditions and assumptions of the exposures 

that may have been observed beyond the single 1952 TWA study conducted by HASL. While the data 

from the site indicated that the bounding operation was from exposure at the rolling mills, NIOSH has 

also included data from rolling and machining operations in TBD-6000 to estimate exposures at Joslyn. 

The surrogate data utilized for the rolling and machining operations came from a study by Christofano 

and Harris (1960), which was a comprehensive peer-reviewed publication that analyzed 60 complete 

surveys from 7 different AEC uranium facilities. The data set included more than 20,000 dust samples 

taken in operator breathing zones as well as general areas beginning in 1948. This publication therefore 

represents a robust data set useful in representing exposures. 

NIOSH compared the data from the 1952 air monitoring results in Table 6-1 of the Addendum of the 

Joslyn Evaluation Report to the daily weighted average values contained in Tables 7.3 and 7.5 of TBD6000. Comparison of these datasets show that the TBD-6000 Machining Operator (GM=2,491 pCi/m3 

, 

95th percentile 35,171 pCi/m3

) and the Rolling Operator (GM=1,606 pCi/m3, 95th percentile 22,675 

pCi/m3

)

2

 provide conservative surrogate data substitutions for both categories. While NIOSH 

acknowledges there was burning of uranium waste outside of the facility, the ABRWH working group has 

previously agreed that those conditions are bounded by the rolling and machining operations represented 

in TBD-6000. 

Further comparison of the data shows that this claimant favorable approach is clearly conservative as 

compared to the TWA rolling mill and machining operator values determined by HASL in 1952, with one 

exception (see Attachment 1). In TBD-6000, the geometric mean of the rolling mill operator is less than 

the HASL measured values at the east and west side of the 9” finishing rollers. While the TWA 

determined by HASL for those operators was 7451 (with a maximum value 17,672 pCi/m3

), the exposure 

is contained within the bounds of the distribution provided by the Rolling Operator (95th percentile 22,675 

pCi/m3

). Furthermore, after July 1948, the contracts under which Joslyn operated for the Joint Rolling 

Program on Dimensional Stability (AEC and Atomic Energy Commission Canada) specifically called for 

rolling on the 18 inch mill (summary of rollings are contained in part in SRDB 118159, SRDB 120484, 

SRDB 04048, and SRDB 112574). This program represented smaller efforts (approximately 30 tons in 

each 1949 and 1950) compared to the production rates Joslyn experienced in early 1948. The 18-inch 

rolling mill was also shown in the 1952 study to have substantially lower air concentrations compared to 

the 9-inch finishing mill. The use of the 18-inch mill removed the highest source of exposure at Joslyn 

from many of days of operations and further substantiates that multiple mills were not used 

2

 The air concentration values for the machining operator and rolling operator were derived from the stated pCi/d intakes in TBD- 

 6000. The 95th percentile values were computed using the TBD-6000 assumption of a GSD of 5. 

Page 4 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

simultaneously during this time period because of the careful temperature control called for in the 

program. NIOSH knows of only one rolling event beginning in August 1948 where the 9-inch mill was 

used (January 1952, when HASL conducted the TWA study). Worker testimony in the 2012 outreach 

meeting by a worker who was in the mill area beginning in 1948 only remembered using the 18-inch mill 

for uranium work (SRDB 118494). 

3) Site or Process Similarities – One of the key criteria for judging the appropriateness of the use of 

surrogate data would be the similarities between the site (or sites) where the data were generated and 

the site where the surrogate data are being utilized. The application of any surrogate data to an 

individual dose reconstruction at a site should include a careful review of the rationale for utilizing 

that source of data. Factors that could be considered include, but are not limited to, similarity of the 

production processes, presence or absence of conditions that might affect exposure, and monitoring 

methods employed at the site(s). The potential availability of other sources of surrogate data needs to 

be considered and the selection of the surrogate data used for dose reconstruction justified. Some of 

the questions to be considered where appropriate are: 

i) Are there other sources of surrogate data that were not used? 

ii) Do these other potential sources contradict or undermine the application of the data from the 

selected site? 

iii) Are there adequate data characterizing the site being used that would help support its 

application to other sites? 

iv) Do the surrogate data reflect the type of operations and work practices in use at the facilities 

in question? 

v)	 Surrogate data should not be used if the equivalence of working conditions, source terms, 

and processes of the surrogate facility to the one for which dose reconstructions are being 

done cannot be established with reasonable scientific or technical certainty as outlined here. 

TBD-6000 provides a comparison of data across a number of facilities that conducted exactly the same 

types of rolling and machining operations that Joslyn performed. Review of the site data available from 

1951 and 1952 shows that the rolling operations provided the highest measured exposures at the site and 

all operations measured on those days were found to compare very well with the distribution of data 

provided in TBD-6000 (see Attachment 1). NIOSH believes that these comparisons provide convincing 

evidence that the TBD-6000 data provide a realistic exposure assessment for operations at Joslyn. As 

previously discussed, the HASL laboratory utilized well described methods of collection, analysis and 

evaluation that reflect state of the art at the time. 

NIOSH made the determination that conditions at Joslyn met with the process similarities of the facilities 

at which HASL made the measurements upon which TBD-6000 is based beginning with August 1, 1948. 

NIOSH carefully considered the following items: 

•	 Beginning with August 1948, Joslyn was operated with AEC oversight which provided increased 

certainty that the air monitoring data from other facilities is appropriate for comparison. 

Page 5 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

Documented AEC oversight and presence for the operations conducted after the completion of 

the production campaigns that were completed in July 1948, coupled with well-defined and 

specific operations, allowed NIOSH to conclude the data obtained by HASL in 1951 and 1952 

could be represented by the exposure conditions in TBD-6000 as early as August 1, 1948. 

•	 Beginning in August 1948, the reduction in production levels to smaller rolling operations in 

support of specific research projects were less likely to have required simultaneous rollings on the 

three closely-located rolling mills. 

•	 Beginning in August 1948, the contracts under which Joslyn operated for the Joint Rolling 

Program on Dimensional Stability (AEC and Atomic Energy Commission Canada) specifically 

called for rolling on the 18 inch mill. This removed the highest source of exposure (the 9” rolling 

mill) at Joslyn during many of the days of operation and provides additional evidence that 

multiple mills were not used simultaneously during this time period. 

4) Temporal Considerations: Consideration also needs to be given to the period in question, since 

working conditions and processes varied in different periods. Surrogate data should belong in the 

same general period as the period for which doses are sought to be reconstructed unless it can be 

demonstrated that the working conditions, procedures, monitoring methods, and (perhaps) legal 

requirements were comparable to the period in question. 

Temporal considerations for Joslyn were given extensive weight when determining the feasibility of dose 

reconstruction and the comparability of surrogate data that could be used for dose reconstruction and 

these have been discussed in the previous sections. It is particularly important, however, to note that 

Joslyn only used electrically heated furnaces to pre-heat the billets, unlike other later-constructed facilities 

that may have used lead or salt bath coatings. NIOSH confirmed that the TBD-6000 data set extended to 

cover the Simonds Saw and Steel initial studies with rolling furnace heated uranium and thus extend the 

applicability of TBD-6000 back to 1948. 

5) Plausibility: The manner in which the surrogate data are to be used must be “plausible” with regard 

to the reasonableness of the assumptions made. The plausibility determination should address issues 

of: 

a) Scientific plausibility. Are the assumed models (e.g., bioassay, concentration gradients) 

scientifically appropriate? Have the models been validated (where feasible) using actual 

monitoring data collected in a similar situation? 

b) Workplace plausibility. Are the assumed processes and procedures (including monitoring) 

plausible for the facility in question? Have all of the factors that could significantly impact 

exposure been taken into account? Is adequate information available about the facility in order to 

be able to make a fair assessment? 

While the data from the site indicated that the bounding operation was exposure at the rolling mills, 

NIOSH has used data from both the rolling mill and machining operator category from TBD-6000 to 

provide a reasonable estimate of exposure at Joslyn beginning August 1, 1948. The surrogate data utilized 

Page 6 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

for the rolling and machining operations came from a study by Christofano and Harris, which was a 

comprehensive peer-reviewed publication that analyzed 60 complete surveys from 7 different AEC 

uranium facilities. The data set included more than 20,000 dust samples taken in operator breathing zones 

as well as general areas beginning in 1948. This publication therefore represents a robust data set useful 

in representing exposures that have been shown for this site and others to represent a fair, scientifically 

plausible, and complete method to describe dose reconstruction methods at Joslyn after July 31, 1948. 

NIOSH used site data to verify that the TBD-6000 approach produced reasonable, claimant favorable 

estimates for the many different machining and rolling operations at Joslyn. NIOSH further reviewed 

carefully the operational characteristics and temporal changes at Joslyn to come the conclusion that this 

was an appropriate method for dose reconstruction. The changes to the rolling schedules and significantly 

reduced use of the highest exposure rolling mill (the 9-inch finishing mill) after July 31, 1948 further 

lends itself to the conclusion that TBD-6000 provides conservative and reasonable uranium intakes at 

Joslyn. 

Page 7 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

 

 

 

 

 

 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

Attachment 1: 

Comparison on Time Weighted Average Study with TBD-6000 (from Table 7-1 of the Evaluation Report 

Addendum) 

Table 7-1: Comparison of 1952 Time-weighted Average (TWA) Study with Battelle-TBD-6000 

Joslyn Work Area/Job Description 

TWA 

(pCi/m3

) 

Battelle-TBD-6000 

Equivalent Description 

GM 

(pCi/m3) 

95% 

(pCi/m3) 

AM 

(pCi/m3) 

18" rough roll east 1496 Rolling Operator 1606 22675 5864 

18" rough roll west 169 Rolling Operator 1606 22675 5864 

Roller Forman 327 Rolling Supervisor 148 2090 540 

Asst Roller (Ass't Foreman) 327 Rolling Supervisor 148 2090 540 

Furnace Heaters 7 Rolling General Labor 296 4179 1081 

Recorder 7 Rolling General Labor 296 4179 1081 

12" rough Roll East 273 Rolling Operator 1606 22675 5864 

12" rough Roll West 257 Rolling Operator 1606 22675 5864 

Drag Down (Billet) 140 Rolling General Labor 296 4179 1081 

9" finishing roll east 7451 Rolling Operator 1606 22675 5864 

9" finishing roll west 2609 Rolling Operator 1606 22675 5864 

Quench Tank 70 Rolling General Labor 296 4179 1081 

Draggers 374 Rolling General Labor 296 4179 1081 

Rod Stamper 109 Rolling General Labor 296 4179 1081 

Rod Bundler 58 Rolling General Labor 296 4179 1081 

Lathe Operation 5 Machining Operator 2491 35171 9096 

The 1952 study presented in Attachment 1 is the only time-weighted-average (TWA) study located for 

Joslyn. As can be seen, each arithmetic mean (AM) of the distribution with the given geometric mean 

(GM) and a geometric standard deviation (GSD) of 5 is generally much higher than the 1952 TWA values 

obtained at Joslyn. In one location (“9-inch finishing roll east”), the Joslyn value is higher. 

Page 8 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution. 
 

 

White Paper, Rev. 0 Joslyn Manufacturing and Supply Co. Use of Surrogate Date April 2014 

References 

ABRWH 2010. Criteria for the use of Surrogate Data, final draft issued May 14, 2010. (This can be 

accessed at <http://www.cdc.gov/niosh/ocas/pdfs/abrwh/proc/abrwh-proc-sd-r0.pdf>. 

Battelle, 2011. Battelle-TBD-6000 Rev 1, Site Profiles for Atomic Weapons Employers that Worked 

Uranium Metals, June 17, 2011 

Christofano, E and WB Harris. 1960. “The Industrial Hygiene of Uranium Refining.” Archives of 

Environmental Health 1(5):74-96 

Klevin, P.B., 1952. Joslyn Manufacturing and Supply Company Occupational Exposure to Radioactive 

Dust; March 25, 1952; SRDB 9664. 

NIOSH 2008. The Use of Data from Other Facilities in the Completion of Dose Reconstructions under 

the Energy Employees Occupational Illness Compensation Program Act, OCAS IG-004, August 2008. 

NIOSH 2012. SEC Petition Evaluation Report SEC-00200, Joslyn Manufacturing. National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. December 3, 2012. 

NIOSH 2014. SEC Petition Evaluation Report Addendum SEC-00200, Joslyn Manufacturing. National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. January, 2014. 

Piccot, A.R., 1949. Residual Contamination Survey at Joslyn Steel Co.; August 22, 1949, 11036, PDF pp. 

46–50; 9663, PDF pp. 6–14. 

Page 9 of 9 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review 

contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by 

NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy 

Act 5 USC §552a and has been cleared for distribution.